The Medicare physician fee schedule 2026 (CY 2026 PFS proposed rule) signals meaningful shifts that every practice owner should watch. From Medicare payment schedule updates for RPM and telehealth to changes in practice expense methodology, the Medicare fee schedule is the blueprint that will determine how solo and small practices get paid in 2026. If you run a solo or small practice, this guide distills what matters: how payment updates affect your margins, what to change in your documentation and workflows, and the fast moves that protect cash flow in 2026. We cite the Federal Register and CMS fact sheet so you can make decisions with confidence. (Federal Register, Centers for Medicare & Medicaid Services)
Snapshot—What CMS Proposed for 2026 (in Plain English)
- Potential payment increase overall: News coverage notes physicians could see a ~3.3–3.8% bump depending on program participation—an inflection after years of erosion. Your mileage varies by mix (time-based codes, site of service, and policy impacts). (Axios)
- Telehealth & supervision modernized: CMS proposes real-time audio-video “direct supervision” for a broad set of incident-to services (and more), permanently aligning policy with virtual workflows. Frequency caps ease for some telehealth services. (National Law Review, Foley & Lardner LLP)
- RPM/RTM flexibility: New 2–15 day device supply codes proposed (in addition to 16+ day 99454), plus rebasing practice expense with auditable OPPS data—aiming for more realistic reimbursement. (National Law Review, OpenLoop Health, Windham Brannon)
- Practice Expense (PE) restructuring: Methodology shifts propose allocating more indirect costs to office settings and using OPPS cost report data to set practice expense inputs—important for specialties dependent on PE. (Windham Brannon)
For exact policy language, rely on the Federal Register posting and CMS’s official fact sheet. (Federal Register, Centers for Medicare & Medicaid Services)
Why Solo & Small Practices Should Care
Margins Can Improve—If You Align Your Mix
Under the Medicare physician fee schedule 2026, a small shift in time-based services—care management, RPM, psychotherapy, and complex visits—can outweigh efficiency adjustments and stabilize revenue. Doctors should view the Medicare fee schedule not just as a payment chart, but as a strategic roadmap for aligning service mix with profitability. Policy analysts highlight better recognition for primary-care-heavy, time-based coding. (Axios)Beyond payer updates, attracting new patients can also protect margins.
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Telehealth Supervision = Staff Leverage
Virtual direct supervision lets you redesign MA/RN/NP support under physician oversight from another location (live audio-video). That expands same-day capacity and helps rural/house-call workflows without compromising compliance. (National Law Review, Foley & Lardner LLP)
RPM Becomes Easier to Fit into Real Life
Many patients don’t always produce 16+ days of readings. The proposed 2–15 day device code fills that gap, so fewer cohorts fall through the cracks. That’s material for HTN, CHF, COPD, obesity, and DM programs. (National Law Review, OpenLoop Health)
Telehealth in 2026—What’s Changing and How to Use It
- Virtual direct supervision broadened: near-universal coverage for incident-to, and even for cardiac/pulmonary rehab, is proposed. That’s a big operations unlock. (National Law Review)
- Telehealth list process simplified and some frequency limits removed—less administrative friction to keep services available. (National Law Review, Foley & Lardner LLP)
- As you expand telehealth offerings, ensure your digital front door is equally effective with Healthcare Website Design
Action to take:
- Update your supervision policies and train staff on compliant audio-video oversight.
- Build tele-triage blocks (RN/MA) under physician supervision to pre-assemble documentation, quality gaps, and care-management opportunities before the MD visit.
Ensure your EHR templates capture supervision mode + participants automatically (defensible audit trail).
RPM & RTM in 2026—Revenue Without Rework
The New RPM Device Supply Option (2–15 Days)
As part of the Medicare physician fee schedule 2026, CMS proposes adding a new device supply code to reimburse 2–15 days of data within a 30-day period. This update makes the physician fee schedule far more realistic for chronic care programs, reducing lost reimbursement opportunities when patients don’t meet the old 16-day threshold. (National Law Review, OpenLoop Health, Windham Brannon)
What this means:
- You can enroll broader cohorts (e.g., post-discharge, exacerbations, titration periods) without missing device supply reimbursement just because a patient produced 10–12 valid days.
- Care pathways for HTN/DM/COPD become more predictable; fewer patients “fall outside billing rules.”
RPM Playbook for 2026:
- Define two cohorts: Intensive (16+ days) and Short-episode (2–15 days).
- Automate eligibility checks, device dispatch, and time tracking for 99457/99458.
- Track weekly engagement KPIs: active devices, adherence %, escalations, and time logged.
- Update ABNs/consents and privacy notices to reflect RPM workflows.
For final policy specifics (codes, thresholds), always confirm in the final rule when published. For now, base operations on the proposed rule & fact sheet. (Centers for Medicare & Medicaid Services)
Practice Expense (PE) & Payment Methodology—Who Wins?
CMS proposes restructuring PE with auditable hospital OPPS data and shifts that allocate more indirect costs to office settings. If finalized, office-based specialties that rely on PE (e.g., primary care using staff & devices) may see fairer expense recognition versus legacy survey-driven methods. (Windham Brannon)
Implication:
- Re-model your 2026 projections with payer mix × code mix × site of service—especially if you run care-management lines or use diagnostic devices.
Watch your PE-heavy services; some may improve relative to 2025.
Tying It to Value-Based Care & Care-Management Lines
CMS continues to steer practices toward coordinated, time-based services—CCM, PCM, BHI, and RPM—that improve outcomes and reduce downstream costs. As margins tighten on some procedural services, these time-based codes protect revenue and support quality metrics for ACO or advanced models. (Centers for Medicare & Medicaid Services)
Operational bundle that works:
- CCM (99490/99439) for multimorbidity
- PCM (G2064/G2065 or current equivalents) for single high-risk condition
- BHI (99484, 99492–99494) integrated with primary care
- RPM (99453/99454/99457/99458 + proposed short-episode device code) for vitals-driven cohorts
Pair with telehealth supervision to scale your team without sacrificing compliance. (National Law Review)
Risk: The “Efficiency” Pressure & Documentation Discipline
Even with an overall bump reported in media, practices can still feel relative cuts depending on service mix and efficiency adjustments. Documentation that supports medical necessity, time, and supervision is non-negotiable. (Axios)
Documentation Checklist for 2026:
- Supervision mode (in-person vs real-time audio-video) and who supervised. (National Law Review)
- Time statements for CCM/PCM/BHI/RPM interactive communication (99457/99458).
- Device adherence days (2–15 vs 16+) + alerts resolved. (National Law Review)
- Problem-oriented notes that reflect decision making (avoid downcoding).
Modifiers/add-on codes where appropriate.
Five Moves to Make Before January 1, 2026
- Build your 2026 code-mix model
Forecast under two RPM cohorts (2–15 & 16+ days), and layer in CCM/PCM/BHI + likely visit mix. Stress-test cash flow. (National Law Review) - Implement virtual direct supervision SOPs
Update policies, consent, and EHR fields to capture real-time audio-video supervision. Train MAs/RNs on tasking and documentation. (National Law Review) - Tighten PE-sensitive services
Re-price costs, evaluate buy-vs-lease on devices, and benchmark staff utilization under the proposed OPPS-based PE methodology. (Windham Brannon) - Refresh care-management programs
Confirm patient eligibility lists monthly. Avoid missed CCM/PCM/BHI opportunities. Align with value-based contracts where applicable. (Centers for Medicare & Medicaid Services)
Educate providers on time & necessity
Short micro-trainings reduce downcoding and denials and can lift net collections without increasing volume.
What This Means for Specific Specialties
- Primary Care / Family Medicine / IM: Heavily time-based; RPM + CCM + BHI plus easier tele-supervision can materially improve margins. (Axios)
- Cardiology / Pulmonology: RPM cohorts fit disease management; supervision flexibility helps NP/PA-led workflows. (National Law Review)
Psychiatry / Behavioral Health in Primary Care:BHI models scale with collaborative care and supervision updates. (National Law Review)
Conclusion—Turn Policy into Profitability (Without Overtime)
The Medicare physician fee schedule 2026 is more than a policy update—it’s an opportunity for solo and small practices to thrive. By leveraging changes in telehealth supervision, RPM reimbursement, and practice expense methodology, practices can finally align with a Medicare fee schedule that rewards coordinated, time-based care instead of volume alone.The practices that standardize documentation, stand up care-management lines, and model their 2026 mix now will enter January confident, compliant, and cash-flow ready. (Centers for Medicare & Medicaid Services)
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FAQ
Q1: What is the Medicare physician fee schedule and why does the 2026 proposed rule matter?
It’s the national payment system for Part B services. The 2026 proposed rule updates telehealth supervision, RPM device supply options, and practice expense methodology—changes that can affect your revenue and staffing model. (Federal Register, Centers for Medicare & Medicaid Services)
Q2: Will Medicare payments increase in 2026?
Media summaries indicate a ~3.3–3.8% increase overall, but impact varies by specialty and service mix. Time-based care often benefits. Always confirm in the final rule. (Axios)
Q3: How does the new RPM 2–15 day device code help?
It reimburses shorter episodes that previously missed the 16-day threshold, enabling more realistic chronic care pathways. (National Law Review)
Q4: What does virtual “direct supervision” via audio-video enable?
Physicians can supervise staff remotely in real time for many incident-to services, improving flexibility and capacity. (National Law Review)
Q5: Where can I read the official 2026 proposal?
The Federal Register posting and the CMS fact sheet describe the proposed updates and timelines. (Federal Register, Centers for Medicare & Medicaid Services)
Notes on Compliance & Accuracy
This post summarizes the proposed rule. Policies may change in the final rule. Always confirm final details with your compliance team and the published final rule. (Federal Register)
